BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D. C. 202660001
POSTAL RATE AND FEE CHANGES, 2000
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Docket No. R2000-1
INTERROGATORIES OF ADVO, INC.
TO UNITED STATES POSTAL SERVICE WITNESS
I LOYD RAYMOND (ADVOIUSPS-T13-I-23)
Pursuant to sections 25 and 26 of the Rules of Practice, Advo, Inc. (Advo)
directs the following interrogatories to United States Postal Service witness Lloyd
Raymond. If the witness is unable to respond to any interrogatory, we request that a
response be provided by appropriate USPS witness capable of providing an answer.
Respectfully submitted,
W. McLaughlin
v Thomas
Burzio & McLaughlin
1054 31st Street, N.W.
Washington, D. C. 20007
Counsel for ADVO, INC.
CERTIFICATE OF SERVICE
I hereby certify that I have on this date served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
February 22,200O
ADVO, INC. INTERROGATORIES TO USPS WITNESS LLOYD RAYMOND
ADVOIUSPS-T13-1.
On page 5 of your testimony, you state:
“The objective of the Engineered Standards was to collect actual
activities of the city letter carrier and to develop engineered methods and
time standards to establish a workload managing system.
The data
collected needed to be comprehensive in order to support in-depth
analysis and validation of work methods.”
(4
From the data presented in your testimony, were engineered methods
and time standards developed to establish a workload managing
system? Please explain and describe how the data were used in these
capacities.
(b)
Were the data presented in your testimony used to support any in-depth
analyses or validations of work methods? Please explain and describe
how the data were used in these capacities.
ADVOIUSPS-T13-2.
With respect to the specific project which generated the data
presented in your testimony, please provide the following:
(a)
A full description of your original work plan proposed to the USPS for
each contract you performed on this specific project.
(b)
The statement of work and list of deliverables for each contract you
performed on this specific project.
(4
List of reports, analyses, and all other documentation you prepared on
each contract you performed on this specific project.
(d)
Contract initiation and completion dates for each contract you performed
on this specific project.
-2ADVOIUSPS-T13-3.
With respect to specific project which generated the data
presented in your testimony, please provide all USPS written guidance and describe
all discussions with the USPS concerning
(a)
the selection of specific locations and routes for observation.
(b)
the observation approach, activities to be recorded, and the criteria for
the data collection for this project.
Cc)
data processing and quality assurance procedures.
ADVO/USPS-T13-4.
What documentation did you review or assess on either sites,
locations or routes prior to the selection process?
ADVOIUSPS-T13-5.
What documentation did you review or assess on either sites,
locations or routes once the sites/locations were selected?
ADVOIUSPS-T13-6.
Were any of the data included within your project data (the
Engineered Standards/Delivery Redesign project, described on page 3 of your
testimony) collected by USPS employees or other contractors (rather than your own
organization)?
If so, please:
(a)
Identify and describe such data.
(b)
Identify the types of USPS employees/contractors that provided the data.
(4
Describe how you validated that data.
ADVOIUSPS-T13-7.
On page 14 of your testimony, you state that during Phase 1, 106
routes were observed at 32 locations.
(4
Please identify the 32 locations in Phase 1 and identify the USPS
Regions in which they are located.
-3(b)
Which locations were chosen by USPS Region personnel which were
chosen by the random-number selection?
(c)
Were there any locations initially chosen by either USPS Region
personnel or the random-number selection that ultimately were not
observed? If so, please provide the number of such locations and
explain why they were not observed.
(d)
Were there any routes initially chosen by the random-number selection
that were not observed? If so, please provide the number of such
locations and explain why they were not observed.
W
Were any observed routes chosen by other than the random-number
selection process? If so, please identify them and explain why they were
chosen.
ADVOIUSPS-Tl3-6.
You state that Engineering sent requests to the ten geographic
USPS Regions asking that each Region select 3 to 5 sites (zip codes). Please
provide a copy of those requests, and any other guidance that was provided to the
Regions, with respect to making choices of sites. If any of the guidance was oral in
nature, please also describe it.
ADVOIUSPS-T13-9.
On page 14 of your testimony, you state that 234 routes were
observed at 22 locations during Phase 2. On page 6 you state that ten “sites” were
selected as potential implementation test sites, which Delivery Redesign reduced to
five implementation test-sites. On page 9 (footnote 8) you also state that two sites
from Phase 1 were also observed. Please identify the number of sites/locations in
Phase 2 that were chosen from
(4
the Phase 2 requests to the ten geographic Regions,
(b)
the Phase 1 requests, and
-4(4
the Phase 1 “random” selection.
ADVOIUSPS-T13-10.
(4
For the Phase 2 locations,
Please identify the 21 locations in Phase 2 and identify the USPS
Regions in which they are located.
lb)
Which locations were chosen by the Regions and which were chosen by
the random-number
(c)
selection?
Were there any locations initially chosen by either the Regions or the
random- number selection that were not observed? If so, please
quantify and explain why.
(4
Were there any routes initially chosen by the random-number selection
that were not observed? If so, please explain why they were not
observed.
(4
Were any observed routes chosen by other than the random-number
selection process? If so, please identify them and explain why they were
chosen.
ADVOIUSPS-T13-11.
On page 6 of your testimony, you state that it was determined
that two-person teams would be required to collect the work sampling data.
(a)
Please explain why two data collectors were required to sample each
route-day.
(b)
Please describe what each data collector did during the data collection
process.
(4
Please identify any route-day where there was only one data collector.
(4
Please identify any route-day where there were more than two data
collectors.
-5ADVOIUSPS-T13-12.
(4
With respect to the Videx TimeWand II Barcode Scanners,
Please provide all documentation available on how to use the
equipment.
(b)
When the six-minute interval tone is programmed, is there a limitation on
when data must first be entered? Is there a limitation on how long it
takes to complete an observation?
w
Is it possible to make corrections to one or more entries on the scanner
during the observation?
Cd)
Do the scanners automatically time and date each observation?
(4
Do the scanners maintain the time sequencing of the observations?
ADVOIUSPS-T13-13.
On page 13 of your testimony, you state that:
“Data collectors printed daily reports which the team reviewed for
accuracy of scans and manual entries. Changes were not made on site:
any changes to the data were noted and forwarded to the central
database managers. After being reviewed, the data was uploaded to a
central database.”
(4
Please provide all written instructions and criteria given the data
collectors on how they were to review for accuracy of scans and manual
entries.
(b)
Were there supervisory individuals on site/location who reviewed the
accuracy of scans and manual entries? If so, provide all written
instructions and criteria given to those individuals on how they were to
review for accuracy.
(4
With respect to the forwarded changes from on-site, please quantify the
following:
(1)
The number of route-days which were noted as requiring some
change.
-6(2)
The number of individual observations by route-day which were
noted as requiring some change.
(4
Please provide a list of all the types of changes that were forwarded.
ADVOIUSPS-T13-14.
With respect to the central database managers for this project,
please provide:
(4
copies of all training and instruction manuals.
(b)
a description of the training of the central database managers, and
(c)
an explanation of how the database managers ran and reviewed the
daily reports.
ADVOIUSPS-T13-15.
With respect to the changes made by the central database
managers
60
Were there occasions when the changes forwarded from the site were
not implemented by the database managers? Please explain and
quantify by route-day.
(b)
Were there occasions when the database managers made changes
which were different from those forwarded from the site? Please explain
and quantify.
(a
Please provide a list of all the types of errors identified by the database
managers. If they can be quantified by type, please do
(4
SO.
When these types of errors were resolved, please explain generally how
they were resolved.
(6
Please describe the types of “outliers” that were investigated.
ADVOIUSPS-T13-16.
With respect to errors that were purged from the data set:
-7-
(4
Please provide a list of all the types of errors that were purged and how
your organization attempted to resolve them before purging them. If they
can be quantified by type, please do so.
(b)
When there was an unresolved apparent error in only one or a small
grouping of observations, were only those observations (tallies)
eliminated or was the entire route-day eliminated?
Please explain.
w
Please quantify the number of full route-days that were purged.
(d)
Please quantify the number of observations (tallies) that were purged on
route-days that remained in the database.
(4
Please quantify the number of route-days for which only some
observations (tallies) were purged.
ADVOIUSPS-T13-17.
For each route code, from the data you collected on location,
please provide the number of possible:
(a)
(b)
w
03
(e)
(9
(9)
03
Residential
Residential
Number of
Number of
Number of
Number of
Number of
Number of
ADVOIUSPS-T13-18.
curb deliveries
NDCBU deliveries
residential centralized deliveries
other residential deliveries
business curb deliveries
business NDCBU deliveries
business centralized deliveries
other business deliveries.
For each route/day, from the data you collected on location,
please provide the number of actual deliveries made. If possible separate them by
type:
(a)
(b)
(cl
Residential curb deliveries
Residential NDCBU deliveries
Number of residential centralized deliveries
-8(4
(e)
(9
(9)
0’0
Number
Number
Number
Number
Number
ADVOIUSPS-T13-19.
of
of
of
of
of
other residential deliveries
business curb deliveries
business NDCBU deliveries
business centralized deliveries
other business deliveries.
With respect to the use of the Engineered Standards data for
“support/update” of the Street-Time Survey (STS):
(4
When were you first advised that data from the Engineered Standards
data collection might be used for postal rate case costing purposes as a
“support/update” for the Street-Time Survey (STS)?
(b)
Please identify all the USPS and USPS contractor representatives with
whom you discussed the use of the ES data for suppotiupdate
of the
STS, and when you first discussed it with them.
(c)
Please provide copies of all requests, proposals, instructions and
correspondence with the USPS and/or USPS contractor representatives
relating to such use of the ES data.
Did you review any documentation for the Street-Time Survey? If SO,
what STS documentation did you review, and when did you review it?
(6
Did you review any documentation on the Foot Access Test, the Curbline
Access Test, or the Load Time Variability Test? If so, what
documentation did you review, and when did you review it?
ADVOIUSPS-T13-20.
Did the USPS or any USPS contractor provide any written or oral
guidance or assistance on how to translate the individual observations/tallies in your
data into the six STS categories? If so, please identify those individuals, provide
copies of any written guidance or assistance, and describe any oral guidance or
assistance.
-9ADVOIUSPS-T13-21.
Please explain how the out-of-office observations were initiated
and ended.
(4
Did the data collectors identify the check-out time when carriers left for
the street or the check-in time when they returned to the office?
lb)
For any one route, at what points were the Videx TimeWand II Barcode
Scanners initiated to start counting six minute intervals at the beginning
of out-of-office time and for the end of lunch break? Did this vary by
route?
(4
For any one route, at what points were the scanner stopped for lunch
break and for the end of out-of-office time?
ADVOIUSPS-T213-22.
On page 14 of your testimony, you state:
“The scan sequence for each line of the database was reviewed and
one of the STS categories was entered.
To crosscheck the manual
review process, a master list of scan sequences were grouped
according to STS activity. All scan-sequence possibilities for an STS
activity were assigned a l-6 code. An update query was then used to
assign the sequences a code in the database. These codes appear in
the Library Reference USPS-LR-I-163 with the column header “STS
Type.”
(a)
Was the initial assignment to STS category done manually? If so, who
was responsible for the assignment and at what point in the processing
was it done?
(b)
On page 14, you state that the column “STS Type” contains the
definitions entered by manual sequence review, but on page 15 you
state that this column contains the numeric codes assigned by the
master list. Please explain.
(c)
How was the master list used to crosscheck the manual sequence
review?
(d)
Please provide the master list of scan sequences.
-lO-
7ADVOIUSPS-T13-23.
Please provide the following information with respect to the
sample survey that generated the data presented in your testimony and used by
USPS witness Baron:
(a)
the “definition of the universe under study, the sampling frame and units,
and the validity and confidence limits that can be placed on major
estimates,” as required by Rule 31(k)(2)(ii) of the Commission’s Rules
of Practice.
(b)
a description of all sampling and statistical tests performed with respect
to the data collection.
(c)
the results of all such sampling and statistical tests.